Document from CIS Legislation database © 2003-2019 SojuzPravoInform LLC


of January 26, 2001

About avoidance of double taxation concerning taxes on the income and on the capital

Government of the Kyrgyz Republic and Council of the Swiss Federation,

wishing to develop and strengthen economic, scientific and technical cooperation between two States, and for this purpose to sign the Agreement on avoidance of double taxation concerning taxes on the income and on the capital,

agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons which are residents of one or both Contracting States

Article 2. Taxes to which the Agreement extends

1. This agreement is applied to taxes on the income and on the capital levied on behalf of one of Contracting States or its political divisions, or regional authorities irrespective of method of their collection.

2. All taxes levied from the total amount of the income on the total amount of the capitals, or from separate elements of the income or the capitals, including the taxes levied from the income from alienation of personal or real estate, the taxes levied from the total amount of the salaries or salaries paid by the companies and also the taxes levied from the income from capital gain are considered as taxes on the income and on the capital.

3. The existing taxes to which the Agreement extends are in particular:

a) in Kyrgyzstan:

(1) the income tax and the income from legal entities;

(2) income tax,

(further mentioned as "the Kyrgyz tax");

b) in Switzerland:

Federal, cantonal and municipal taxes:

(1) on the income (for the total amount of the income, on earned incomes, on capital revenues, on profit on production and trade on the main earnings and other income items); and

(2) on the capital (on cumulative property, personal and real estate, business assets, the paid part of share capital and reserve fund and other components of the capital),

(further mentioned as "the Swiss tax").

4. The agreement is applied also to any identical or in essence to similar taxes which will be levied after signature date of this agreement in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes accepted in their corresponding tax legislations.

5. The agreement is not applied to the taxes withheld from sources of payment of prizes on lottery.

Article 3. General determinations

1. For the purposes of this agreement if other does not follow from context, then:

a) (1) the term "Kyrgyzstan" means the Kyrgyz Republic. In case of the use in geographical names the term "Kyrgyzstan" means the territory over which the Kyrgyz Republic performs the sovereign rights and jurisdiction according to International law and on which the tax legislation of the Kyrgyz Republic acts;

(2) the term "Switzerland" means the Swiss Confederation;

b) the term "person" includes physical person, the company and any other consolidation of persons;

c) the term "company" means any legal entity or any other organization considered as the legal entity for the purpose of the taxation;

d) the term "company of one Contracting State" and "company of other Contracting State" means respectively the company managed by resident of one Contracting State and the company managed by resident of other Contracting State;

e) the term "international delivery" means any transportation sea either the aircraft, or the land transport operated by the company which actual governing body is in one Contracting State, except as specified, when sea either the aircraft, or the land transport is operated only between Items in other Contracting State;

e) the term means "competent authority"":

(1) from Kyrgyzstan - the Ministry of Finance or its authorized representative;

(2) from Switzerland - the Director of Federal Tax Administration or its authorized representative;

g) the term "national person" means:

1) any physical person having nationality of the Contracting State;

2) any legal entities, partnerships and associations which received the status according to the current legislation of the Contracting State;

h) the term "capital" means personal and real estate and, includes (but it is not limited to them) the cash, shares or other documents confirming property rights, bills of exchange, bonds or other debt obligations, and also patents, trademarks, copyright or other similar rights or property.

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